SEC Comment Letter for Stitch Fix, Inc. (SFIX) (CIK 0001576942) (SFIX) — Feb 25, 2020
Stitch Fix, Inc. (SFIX) (CIK 0001576942)
Date: Feb. 25, 2020 · CIK: 0001576942 · Accession: 0000000000-20-001717
AI Filing Summary & Sentiment
File numbers found in text: 001-38291
Letter
February 25, 2020 Mike Smith Interim Chief Financial Officer Stitch Fix, Inc. 1 Montgomery Street Suite 1500 San Francisco, CA 94104 Re:Stitch Fix, Inc. Form 10-K for the Fiscal Year Ended August 3, 2019 Filed October 2, 2019 File No. 001-38291 Dear Mr. Smith: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended August 3, 2019 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 30 1.We note in your earnings calls that you discuss net revenue per client, success rates of items sent in the first fix during a given period compared to the prior period, and inventory turnover. If these metrics are used by management to manage the business, and promote an understanding of the company’s operating performance, they should be identified as key performance indicators and discussed pursuant to Instruction 1 of paragraph 303(a) or Regulation S-K and Section III.B.1 of SEC Release No. 33-8350. Please tell us your consideration of disclosing these metrics, or other key performance indicators used. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameMike Smith Comapany NameStitch Fix, Inc. February 25, 2020 Page 2 FirstName LastName Mike Smith Stitch Fix, Inc. February 25, 2020 Page 2 You may contact Stephen Kim at 202-551-3291 or Theresa Brillant at 202-551-3307 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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February 25, 2020
Mike Smith
Interim Chief Financial Officer
Stitch Fix, Inc.
1 Montgomery Street
Suite 1500
San Francisco, CA 94104
Re:Stitch Fix, Inc.
Form 10-K for the Fiscal Year Ended August 3, 2019
Filed October 2, 2019
File No. 001-38291
Dear Mr. Smith:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended August 3, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 30
1.We note in your earnings calls that you discuss net revenue per client, success rates of
items sent in the first fix during a given period compared to the prior period, and inventory
turnover. If these metrics are used by management to manage the business, and promote
an understanding of the company’s operating performance, they should be identified as
key performance indicators and discussed pursuant to Instruction 1 of paragraph 303(a) or
Regulation S-K and Section III.B.1 of SEC Release No. 33-8350. Please tell us your
consideration of disclosing these metrics, or other key performance indicators used.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNameMike Smith
Comapany NameStitch Fix, Inc.
February 25, 2020 Page 2
FirstName LastName
Mike Smith
Stitch Fix, Inc.
February 25, 2020
Page 2
You may contact Stephen Kim at 202-551-3291 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services